- Federal Tax Procedure (2024 Student Ed.), SSRN here. This edition has no footnotes and is designed for the federal tax procedure student. I present the core tax procedure information that I feel appropriate for students without the level of detail and distraction offered in footnotes (which are in the Practitioner Edition). Key Code and case citations that the student should know are in the body of the text.
- Federal Tax Procedure (2024 Practitioner Ed.), SSRN here. This edition has the same text as the Student Edition but also offers footnotes that support or discuss points in the text. This edition is more suited to practitioners who may need that level of detail.
I provide resource links in the Appendix to each Edition and in the right-hand column of this Blog.
PERMISSION TO USE. All readers are given permission to use the books. The books are copyrighted, so appropriate credit to the book is appreciated when the contents are used in other publications. Any use (even beyond "fair use" in copyright sense (see here)) is permitted, provided only the proper credit to my publication is given prominently with such use).
UPDATES AND CORRECTIONS. I may offer updates, corrections, changes, etc. (collectively "Updates") through blog entries. Throughout the year, I make many changes to the working draft of the next annual editions. Some of the changes are significant, representing important developments or corrections to errors in the 2024 Editions. For those significant changes, I will post them as blog entries stating the change and referencing the page numbers affected in each Edition. Readers can access updates in either of two ways:
- A blog page (right column) titled Federal Tax Procedure Book 2024 Editions Updates, here. This lists the significant updates and changes to the 2024 Editions by chapter, with appropriate links.
- By blog keyword titled "FTPB 2024 Updates" here . The search results are first generated by relevance, but by clicking a link at the top, you can see the entries in reverse chronological order.
OTHER TAX PROCEDURE SOURCES:
- Procedurally Taxing Blog. This blog is an outstanding source. It formerly was free but is now a subscription service by Tax Notes / Tax Analysts.
- Michael Saltzman and Leslie Book, IRS Practice and Procedure (Thomsen Reuters 2015), here
I highly recommend the most detailed and authoritative discussion of Federal Tax procedure, (Disclosure: I am the principal draftsman of Chapter 12 of that publication, titled Criminal Penalties and the Investigation Function.) That treatise is cited frequently by the courts, from the Supreme Court on down. For those wanting definitive research, that treatise should be consulted. To give you some idea of the depth of the coverage, chapter 12 on Criminal Penalties and the Investigative Function was 311 pages (with footnotes) in the original pdf copy when published in 2015. By contrast, in my Federal Tax Procedure Book Practitioner 2024 Edition (with footnotes), I cover that topic in part of Chapter 6, titled Penalties, in 44 pages. Keep in mind that the principal target for my Federal Tax Procedure Book is the student but provide footnotes in the Practitioner edition to offer more detail but not in any way to compete with the discussion in the Saltzman & Book treatise.
FORMS AND MATERIALS FOR USE WITH THE BOOK:
- Forms. IRS Forms, Instructions & Publications may be obtained from the IRS website of the same name, here. In 2017, I provided a set of forms in pdf format, here, but some of these forms have been revised since 2017. So, be sure and check for any updates on the IRS website.
- Materials. I offer here in pdf format a collection of materials (key cases, select John Doe Summons documents and articles) that I asked the students to read and be prepared to discuss in class, Caveat: I have not updated these materials recently.
- Problem Set. I do not have a problem set for this book. I offer copies of some of my examinations from my most recent years of teaching at the University of Houston Law School (ending in Fall 2015). These questions may span different Chapters of the books, so they may not be suited for chapter-by-chapter discussion of problems. Professors might use the exams might be used to create a chapter-by-chapter problem set. Or Students may use the examinations to review, either for an examination or just general review. Many of the examination questions are based (at least conceptually) on examples given in the text..
- I encourage and value comments (including, most importantly, items that should be corrected, deleted, or included). Comments (including anonymous) may be offered (on this blog page (at bottom) or (ii) emailed to me, jack@tjtaxlaw.com. I will use these comments to make the next edition better and, if appropriate, make updates through the update techniques described above.
- If you are using either Edition for teaching, I would appreciate your advising me. It is always good to know which teachers and classes are using the book.
- I welcome examples of problems that professors use to help their students better understand tax procedure concepts. Perhaps with enough suggestions, I can prepare a set of problems with answers for the book. If I use problems (or reasonable variants) submitted to me, I will give appropriate credit to the professor developing the problems.
EARLIER EDITIONS OF THE FEDERAL TAX PROCEDURE BOOK. These may be downloaded from my SSRN author page, here.
FTPB 2024 STATISTICS.
I offer here the statistics for FTPB 2024.
1. From MS Word (I copied and pasted into MS Word from my primary wordprocessor, WordPerfect):
2. From WordPerfect (my primary word processor)-readability comparisons with Lincoln's Gettysburg Address:
I was curious about WP's maximum words per sentence being 334. Wow! I would like to check that out but don't know an easy way to find that long sentence. I will look for it in my working draft for the 2025 edition; if I find it, I will try to cut it down. But then maybe that'll just move that needle to 330 or some such. In any event, if anyone has some easy way (easy for nontechie guy) to locate long sentences, please let me know.
Also, I have no idea why some of the count measures in MS Word (¶ 1) are different than in WordPerfect (¶ 3). Since WordPerfect has been around in a more stable format for many years, I tend to trust its statistics more. However, when I have time I may do some shorter sample "what-ifs" to see in the differences repeat themselves and whether there is any pattern to the differences.
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